Following discussions between CIOT and HMRC over the last few months, HMRC have made some changes to their guidance in the Company Taxation Manual on the Targeted Anti-Avoidance Rule (TAAR) contained in s396B ITTOIA 2005.

On 3 July 2018, the OECD published a discussion draft on the transfer pricing aspects of financial transactions as part of Actions 8 to 10 (aligning transfer pricing outcomes with value creation) of the Base Erosion and Profit Shifting (BEPS) project.